Edit This Favorite

Jacobi Report Overview: Recommendations

The long awaited Jacobi report has finally been released. After months of anticipation, the Integration of Behavioral and Physical Health Care: Licensing and Reimbursement Barrier and Opportunities in New Jersey written by Seton Hall law professor, John Jacobi was released yesterday.

RECOMMENDATIONSThe report is favorable to the FQHCs and supports our agenda and Senator Vitale’s integration legislation. The recommendations provide the best (and quickest) overview:

New Jersey should move toward a system requiring only a single license for the operation of an integrated facility. Interim steps advancing DOH and DHS toward a single licensure system, such as the collaboration leading to the Shared Space Waiver, should be undertaken to minimize the impediments to implementing clinically appropriate integrated facilities. (p. 86)

Regulatory requirements for separation of behavioral and primary care services should be eliminated, as DOH accomplished with the Shared Services Waiver, except for those, such as records maintenance, required by law. Facilities regulations should be functional, encouraging shared space and services where not inconsistent with patient needs. (p. 87)

Medicaid payment rates for primary care and behavioral health services through fee-for-service and Medicaid managed care organizations should be reviewed in order to assure sufficient levels to permit sustainable integrated care. (p. 89)

DHS, in determining the shape of its fiscal agency model under the Comprehensive Waiver, should consider contracting with a single agent for both physical and behavioral health care claims. (p. 91)

DHS should continue to pursue initiatives such as Behavioral Health Homes and the NJ CCBHC project to ensure that people with serious and persistent behavioral health needs have access to necessary physical health services in an integrated setting. (p. 93)

DHS should use the period of transition to new agents and intermediaries to adjust the terms and conditions of Medicaid participation and payment to facilitate behavioral health integration. (p. 94)

FQHCs should be permitted to maintain or add behavioral health services to screen and provide services for mild to moderate behavioral health conditions without filing a Change of Scope application; the addition of services for severe and persistent behavioral health conditions should, however, trigger such a requirement. (p. 96)

The Department of Human Services and Health should identify staff with responsibility for integration efforts and provide full and public disclosure of their regulatory policies for the benefit of providers and regulatory personnel in the form of:

FAQs and more complete descriptions of regulatory policy on integration on agency web sites

Public outreach to mental health programs, substance use disorder programs, FQHCs and other primary care providers, hospitals, and their trade organizations with full descriptions of agency policy (p. 99)